Order Execution Policy

1. Overview

The purpose of this document is to provide clients of Leodis Wealth with information in relation to our Order Execution Policy.

2. Specific Client Instructions

If you provide us with a specific instruction to deal for you it may prevent us from following our Order Execution Policy which is designed to obtain the best possible result for you on a consistent basis taking into account the factors outlined in section 3.

3. Execution Factors

When dealing for you we will consider:

• Your client classification;

• The characteristics of the financial instrument concerned and of your order; and

• Where such orders can be effected.

In assessing the most appropriate route to carrying out your order we will consider the following criteria:

• Price

• costs of the transaction

• speed of execution

• Certainty of execution and/or settlement

• size and complexity of the order and

• characteristics and nature of the order

The weighting/relevance of these factors may differ between Retail and Professional clients.

When dealing in a financial instrument on your behalf we will exercise our discretion in assessing the criteria that we need to take into account to provide you with the best result (“best execution”). The relative importance of these criteria will be judged on an order-by-order basis in line with our commercial experience and with reference to market conditions.

In executing orders for Retail clients, in the absence of any specific instructions, we generally give precedence to the factors that allow us to deliver the best possible result in terms of value (total cost) to the client.

4. Execution Venues (Competing Markets)

We will regularly assess the execution venues available and may add or delete venues in accordance with our obligation to provide you with the best possible execution result on a consistent basis. We will notify you of material changes to our Order Execution Policy as outlined in section 7.

We can provide a list of the entities on which we place significant reliance for executing orders if required. Please contact us at [email protected] This list will be updated as and when we add or remove entities.

5. Execution Methodology

Having assessed the relevant criteria and any specific instructions provided by you we will select the most appropriate method of execution. This may mean that we rely on third parties for this order execution. As part of our due dilligence, we will consider the Execution Policy of the third party as the decision process.

6. Your Consent

We are required to obtain prior consent to our Best Execution policy; receipt of an order from you after 1 November 2007 will be deemed to be your provision of that consent.

7. Monitoring

Leodis Wealth will actively monitor compliance with its Order Execution Policy and will regularly review it along with its general application. Should a material change occur we will post an updated version of this document on our website.

All clients can request a hard copy of our Order Execution Policy and Execution Entities at any time by contacting their investment manager.